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CMS UK Tax Disputes Digest (Winter 2024)

United Kingdom
07/02/2024
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Welcome to the winter 2024 edition of our UK Tax Disputes Digest: a high-level summary of key developments in contentious tax over the last few months for heads of tax, finance directors, general counsel and other in-house professionals.

As with previous editions, we have seen a continued increase in HMRC activity across various areas. Both individual and corporate taxpayers would be well-advised to check their tax position as soon as possible to prepare for any potential HMRC investigation into their tax affairs.

In this edition, we look at just a few of these developments, including the latest on R&D compliance, HMRC’s new crypto asset disclosure facility, a letter campaign targeting those businesses impacted by OECD Pillar Two, and the latest series of other HMRC nudge campaigns.

We also cover a number of notable tax cases and other interesting procedural decisions. This includes an important Supreme Court decision as to whether shares or options should be treated as “employment-related”, as well as a case from the tribunals concerning an unusual decision to allow tax appeal proceedings to be heard in private.

Click here to read the report.

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